BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARINGS PANEL
IN THE MATTER
of the Resource
Management Act 1991
(‘RMA’) and the Local
Government (Auckland
Transitional Provisions)
Act 2010
AND
IN THE MATTER
of 005 RPS Issues B1.1
Enabling Quality Urban
Growth
AND
IN THE MATTER
of 005 RPS Issues B1.2
Enabling Economic
Wellbeing
SUBMISSIONS ON BEHALF OF
THE GREATER EAST TAMAKI BUSINESS ASSOCIATION, THE MAHUNGA DRIVE
BUSINESS ASSOCIATION, THE ONEHUNGA BUSINESS ASSOCIATION, THE
ROSEBANK BUSINESS ASSOCIATION, AND THE WIRI BUSINESS ASSOCIATION
17 October 2014
Dr Grant Hewison
Agent
Grant Hewison & Associates Limited
PO Box 46397, Ponsonby, Auckland 1011
Ph (021) 577-869
Email: grant@granthewison.co.nz
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CONTENTS
PAGE
Introduction
Overview
Submissions on Proposed Auckland Unitary
Plan (“PAUP”)
Auckland Council Statements and Tracked
Changes Versions
Conclusions
Appendix A
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MAY IT PLEASE THE PANEL:
(1) INTRODUCTION
1. These Submissions are made on behalf of the: Greater East Tamaki Business
Association (2004); Mahunga Drive Business Association (1602); Onehunga
Business Association (2555); Rosebank Business Association (3031), and the
Wiri Business Association (2466) (the “Industrial Business Associations”).
(2) OVERVIEW
2. There are only nine small areas of heavy industry zoned land in the entire
Auckland region (Silverdale, The Concourse (Waitakere), Rosebank, Span Farm
(Waitakere), Onehunga/Penrose, James Fletcher Drive, East Tamaki, Wiri and
Hunua Road (Papakura)). The Unitary Plan does not zone any more heavy
industry land (apart from a small site east of Carbine Road, Mt Wellington)
within the Rural Urban Boundary (‘RUB’).
3. As noted in the legacy Manukau City District Plan, “[t]hese areas are a scarce
resource of major importance because they are areas where potentially noxious
activities can be established with separation from sensitive activities. Therefore,
it is important that the use of this resource be maximised for potentially noxious
activities and not other business activities which can be established in a wide
range of other areas. (Manukau City District Plan, 14.9.6).
4. Directive 6.3 of the Auckland Plan directs us to “protect, enhance and improve
business-zoned areas and business improvement districts”.
5. Population growth means an additional 276,700 jobs will be needed in Auckland
by 2041. As the Auckland Plan noted “Better planning is needed to connect where
people live, where they work and how they get there.”1
6. High concentrations of employment are found in the ‘industrial’ business areas
of Auckland. They are situated along the main southern motorway and the rail
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Auckland Plan, paras 386 and 387
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corridors. There is also an arc of business land running from East Tamaki
through Onehunga/Mangere to the airport, west to Rosebank and to the north,
where concentrations occur along the motorway and major arterials.2
7. There is significant concern over the scarcity of industrial land to meet forecast
demands. Nearly one third of industrial land has been used for non-industrial
purposes over the past decade, principally for retail, office and residential use.
The Auckland Plan states that Auckland’s restricted store of industrial land must
be actively managed to ensure that industrial activity – critical to Auckland’s
economic performance – is not impeded. This requires the safeguarding of
existing industrial-zoned sites, effective reuse of brownfield sites, and the
provision of new industrial-zoned land in suitable locations.3
8. Of equal concern is the increasing impact on the permitted use of industrial land
from nearby sensitive activities (such as residential development). Reverse
sensitivity, particularly associated with permitted noise effects from industrial
activities, is undermining use of industrial land. So too is the layer-upon-layer of
regulation in the Unitary Plan that cumulatively restricts the uses that can be
made of industrial land. Intensive residential development (which in many cases
is being planned close to industrial land) has the potential to exacerbate these
problems.
9. In the view of the Industrial Business Associations, these concerns need to be
emphasised a lot more strongly in the Unitary Plan. It is critical that that the use
of the industrial land (in particular heavy industrial land) be maximised for use
by industrial activities and not for other business, or community activities which can be established in a wide range of other areas – or that activities in
these areas are impeded by nearby land uses sensitive to these activities (such
as residential uses).
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3
Auckland Plan, para 385
Auckland Plan, paras 390 and 391.
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(3) SUBMISSIONS ON PROPOSED AUCKLAND UNITARY PLAN (“PAUP”)
10. The Industrial Business Associations made submissions on B1.1 Enabling
Quality Urban Growth and B1.2 Enabling Economic Wellbeing of the PAUP as set
out in Appendix A below.
11. The Industrial Business Associations submitted that the Unitary Plan should
recognise the importance of business and employment opportunities. They are
concerned about the ‘residential focus’ of the Unitary Plan (i.e. that too much
weight is being given to residential issues over business and employment
needs).
12. They noted that the industrial precincts of Auckland have been competitive in
attracting businesses because of the availability of lower-priced land, larger
sites,
industrial
zoning,
strategic
location (transport,
employees and
infrastructure) and accessibility to markets. They are critically important for
production, manufacturing, distribution, storage, wholesale, construction, and
property/business services. They support employment and wealth generation.
13. It was submitted that industrial zoned land is a precious resource. It must be
protected against the encroachment from general business, retail and residential
use. Open space, recreational use (stadiums), community/social facilities (e.g.
prisons) also encroach on industrial uses. Protecting industrial land for
industrial uses will also ensure business services, office and retail activities are
located elsewhere in town centres.
14. In terms of infrastructure, the Industrial Business Associations submitted that
the Port of Auckland on the Waitemata Harbour was by far the highest value
port in New Zealand and needed to remain so from an economic perspective.
The Industrial Business Associations do not support proposals in the Unitary
Plan that reduce the current and future potential for the Port of Auckland.
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15. The Industrial Business Associations sought amendments to B1.1 Enabling
Quality Urban Growth of the PAUP to recognise the following:
a. The need to support business growth and job creation
b. That
quality
of
life
and
social
well-being
is
influenced
by
business/employment opportunities
c. That development must include an optimisation of the benefits of
business/employment opportunities
d. That Strategic Direction 6 from the Auckland Plan be recognised
16. The Industrial Business Associations sought amendments to B1.2 Enabling
Economic Wellbeing of the PAUP to recognise the following:
a. That high concentrations of important employment are found in the
industrial business areas of Auckland.
b. That the protection and enhancement of these areas is critical for future
business and employment opportunities.
c. That these activities face pressure from higher value activities
including retail, service sectors and, in many places, residential growth.
d. That the Port of Auckland on the Waitemata Harbour be recognised as
very important economic infrastructure.
e. That industrial zoned land be protected against the encroachment from
general business, retail and residential use, open space, recreational use
(stadiums), and community/social facilities.
f.
That Strategic Direction 6.3 from the Auckland Plan be recognised.
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(4) AUCKLAND COUNCIL STATEMENTS AND TRACKED CHANGES VERSIONS
17. The Industrial Business Associations have considered the Statements of Michael
William Tucker (concerning B1.1) and Trevor Stewart MacKie (concerning B1.2)
as well as the Tracked Changes Versions of B1.1 and B1.2.
B1.1 Enabling Quality Urban Growth
18. The Industrial Business Associations support the proposed amendments to the
Auckland Council Tracked Changes Version B1.1. These largely reflect the relief
sought by the Industrial Business Associations in their submissions on the
Unitary Plan. In particular, they support:
a. the amendment to recognise economic well-being in a new bullet point
inserted into the sub-section titled ‘Our sense of place’.
b. the amendment to include the sentence “Resilient infrastructure and
access to a diverse range of business and employment opportunities also
enable both the day to day operation and future growth of Auckland”.
c. the amendment to include the phrase “employment and business
opportunities” in the ‘Supply of Land in appropriate locations’ section.
d. the amendment to include Strategic Direction 6 from the Auckland Plan
concerning the economy.
B1.2 Enabling Economic Well-being
19. The Industrial Business Associations largely support the proposed amendments
to the Auckland Council Tracked Changes Version B1.2. These reflect most of the
relief sought by the Industrial Business Associations in their submissions on the
Unitary Plan. In particular, they support:
a. the inclusion of the sentence in the Explanation “The supply and location,
use and development of business land are important to deliver
employment opportunities and meet communities’ needs arising from
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population growth.” However, the Associations submit that heavy
industrial land, in particular, must be protected and provided for. It is
submitted that the phrase “(especially heavy industrial land)” be
included in the sentence after the words ‘business land’.
b. the inclusion of the sentence in the Explanation: “Auckland is the
location of New Zealand’s largest commercial port and international
airport, both of which generate significant economic benefits by linking
Auckland and New Zealand to the international freight, trade and visitor
markets.”
c. the inclusion of new references to industry in the Urban Form section
(such as particularly recognising the shortage of heavy industry-zoned
land, reverse sensitivity effects, the need to provide for the future growth
of industry, and freight movement)
20. The Industrial Business Associations note that they sought the inclusion of
Strategic Direction 6.3 from the Auckland Plan ‘protect, enhance and improve
business-zoned areas and business improvement districts’, but that this has not
been included. The Associations seek that Strategic Direction 6.3 from the
Auckland Plan be included in B1.2.
21. However, the Industrial Business Associations do not support the following
proposed amendments to the Auckland Council Tracked Changes Version B1.2
and instead seek the following relief:
a. the inclusion in the introduction of the bullet point ‘the provision of
affordable housing’. The Industrial Business Associations hold concerns
that too much weight is already being given to residential issues over
business and employment needs, especially for industrial areas in the
Unitary Plan. This bullet point on affordable housing should be deleted.
b. the inclusion of the phrase in the introduction ‘including the National
Grid’. The Industrial Business Associations submit that energy supply
extends beyond electricity to other energy supplies and the inclusion of
the reference to the ‘National Grid’ over-emphasises this source of
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supply. The Associations also hold concerns about (and have opposed)
the level of protection afforded to ‘National Grid’ transmission lines over
heavy industrial land elsewhere in the Unitary Pan and are concerned
the inclusion here will influence later consideration of those matters. The
reference to the ‘National Grid’ should be deleted from the introduction
and also the bullet “managing land use and development to enable the
efficient and effective operation, maintenance and repair, and the
development of the national grid” in the later section on Energy in B1.2.
(5) CONCLUSIONS
22. Section 62(1)(a) of the RMA identifies that the contents of a Regional Policy
Statement should include the significant resource management issues for the
region. Economic well-being is an important component of overall well-being.
23. The Industrial Business Associations largely support the proposed amendments
to the Auckland Council Tracked Changes Versions of B1.1 and B1.2. These
largely reflect the relief sought by the Industrial Business Associations in their
submissions on the PAUP.
However, as set out above, there remain some
differences, on which the Associations seek relief.
_________________________________________________
Grant Hewison
Agent
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APPENDIX ‘A’ – Unitary Plan - Detailed Submissions
Provision
Part 1 –
Chapter B 1.1
Enabling
quality urban
growth
Support/Oppose
Support partially
The reasons for our
Submission
Relief Sought
The Unitary Plan must
recognise
the
importance of business
and
employment
opportunities. We are
concerned about the
‘residential focus’ of the
Unitary Plan (i.e. that too
much weight is being
given to residential
issues over business and
employment
needs,
especially for industrial
areas).
Amend as follows:
- a bullet point should inserted in paragraph 4 of
the sub-section titled ‘Our sense of place’:

business growth and the support of job
creation
- a phrase should inserted in paragraph 1 of the
sub-section titled ‘Social Well-being’:
Aucklanders’ quality of life and their social wellbeing is influenced by the affordability of
housing, access to quality public open space,
business/employment opportunities and access
to social and community infrastructure.
- a phrase should inserted in paragraph 3 of the
sub-section titled ‘Supply of land in appropriate
locations’:
Auckland faces many challenges in
accommodating growth. Development must
optimise the benefits of transport integrated with
land use, while providing high quality urban
living, lifestyle choices, business/employment
opportunities, a healthy environment and
protection of Mana Whenua interests. A compact
well-designed urban form is the primary
approach to achieving this balance.
- the following Strategic Direction 6 from the
Auckland Plan should be added at the end of this
section:
Develop an economy that delivers opportunity
and prosperity for all Aucklanders and New
Zealand.
Part 1 –
Chapter B 1.2
Enabling
economic wellbeing
Support partially
The Unitary Plan should
recognise
the
importance of business
and
employment
opportunities. We are
concerned about the
‘residential focus’ of the
Unitary Plan (i.e. that too
much weight is being
given to residential
issues over business and
employment needs).
The Port of Auckland is
by far the highest value
port in New Zealand and
for the sake of the
country needs to remain
so. Ports of Auckland is
New Zealand’s largest
and most important
seaport, handling 37% of
the
country’s
total
seaport trade, and 31%
of trade across all ports,
including
airports.
Proposals that reduce
the current and future
needs and potential for
the Port of Auckland
Amend as follows:
- a paragraph should be inserted in the subsection titled ‘Explanation’:
High concentrations of important employment
are found in the business areas of Auckland
situated along the main southern motorway and
the rail corridors (Penrose, Wiri). There is also an
arc of business land running from East Tamaki
through Onehunga/Mangere to the airport, west
to Rosebank and to the north, where
concentrations occur along the motorway and
major arterials (e.g. North Harbour). The
protection and enhancement of these areas are
critical
for
business
and
employment
opportunities
(particularly
those
zoned
industrial).
- a paragraph should be amended in the subsection titled ‘Urban form’:
“These activities face pressure from higher value
activities including retail, service sectors and, in
many some places, residential growth.”
- a paragraph should be inserted in the subsection titled ‘Physical infrastructure’:
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need to be critiqued in
the light of these facts.
The Port of Auckland is by far the highest value
port in New Zealand and for the sake of the
country needs to remain so. Ports of Auckland is
New Zealand’s largest and most important
seaport, handling 37% of the country’s total
seaport trade, and 31% of trade across all ports,
including airports. Approximately $26.4 billion of
trade passes through Ports of Auckland (POAL)
each year made up of $9.6 billion of exports and
$16.8 billion of imports. By value, POAL is New
Zealand’s largest port for both imports and
exports. Of imports through the Ports, 90% is
destined for an area within a 35km radius of the
Ports. Proposals that reduce the current and
future needs and potential for the Port of
Auckland need to be critiqued in the light of these
facts.
- a new sub-section titled ‘Industrial land’ should
be inserted:
Industrial land
Traditionally, the industrial precincts of Auckland
(such as East Tamaki and Onehunga) have been
competitive in attracting businesses because of
the availability of lower-priced land, larger sites,
industrial zoning, strategic location (transport,
employees and infrastructure) and accessibility
to markets. They are critically important for
production, manufacturing, distribution, storage,
wholesale, construction, and property/business
services. They support employment and wealth
generation. Industrial zoned land is a precious
resource. It must be protected against the
encroachment from general business, retail and
residential use. Open space, recreational use
(stadiums), community/social facilities (e.g.
prisons) also encroach on industrial uses.
Protecting industrial land for industrial uses will
also ensure business services, office and retail
activities are located in town centres.
- the following Strategic Directive 6.3 from the
Auckland Plan should be added at the end of this
section:

protect,
enhance
and
improve
business-zoned areas and business
improvement districts.
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